Putting Consumer Duty into Practice

Roger Miles

25 years: Behavoural science & conduct

In this video, Roger explains how financial firms can meet the FCA’s Consumer Duty requirements by focusing on customer-centred conduct. He breaks down the rules into five key questions, shows how to use behavioural science to measure quality, and shares practical tips for reporting outcomes, supporting vulnerable customers, and embedding a culture of good conduct across the business.

Conduct

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Putting Consumer Duty into Practice

8 mins 37 secs

Key learning objectives:

Understand what Consumer Duty requires from financial firms
Outline five key questions to assess your firm’s conduct
Identify practical indicators to evidence good customer outcomes
Understand the role of behavioural science in meeting FCA expectations

Overview:

The Financial Conduct Authority’s (FCA) Consumer Duty sets clear expectations for financial firms to put customers at the centre of everything they do. Firms must demonstrate that their products, pricing, communications, and customer support genuinely meet consumer needs and deliver fair value throughout the product lifecycle. By focusing on five key questions about clarity, suitability, fairness, effectiveness, and support for vulnerable customers, firms can start meaningful conversations that drive better outcomes. The FCA encourages using behavioural science to improve understanding and simplify communications, while emphasising the importance of a strong, customer-focused culture across all levels of the organisation.

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Summary

What does the FCA expect from firms under Consumer Duty?

The Financial Conduct Authority (FCA) expects firms to show that their conduct consistently puts the customer first. This means being able to observe, evidence and report on how your products, services and support are designed and delivered with the consumer in mind. It’s not just about good intentions – it’s about proving good outcomes for customers.

Firms must show that products provide fair value, suit customers’ needs throughout the product life cycle, and that communications are clear and understandable. Service quality should be high, with particular care taken to support vulnerable customers. The regulator expects firms to think ahead, anticipate potential harms and actively design those out of the customer experience.

How can firms break down Consumer Duty into practical steps?

Firms can simplify the rules by using five key questions that reflect the regulator’s focus areas:

Are your customer communications clear?
Are your distribution channels suitable for your target customers?
Is your pricing fair from the consumer’s point of view?
Is your customer support genuinely effective?
How well do you identify and support vulnerable customers?

What kind of indicators help prove compliance?

The FCA doesn’t prescribe fixed measures instead, it expects firms to think for themselves and choose indicators that truly reflect good customer outcomes. That might feel challenging, but it’s actually a great opportunity to have meaningful conversations across teams about what good service looks like.

Some example indicators include:

Readability scores for product literature and terms & conditions
Evidence of process changes to support vulnerable customers
Appointment of a Consumer Duty Champion at Board level
Root-cause analysis of complaints
Customer journey mapping to spot where people drop off or struggle
Product ‘fit’ audits to identify and correct mismatches between products and customer needs

How does behavioural science support the FCA’s approach?

The FCA increasingly uses behavioural science to understand customer experiences and shape its expectations. Firms are encouraged to do the same – for example, by testing how clearly customers understand communications or how real-life situations may create vulnerability.

A key example is the reading age of customer documents. While firms have often assumed an adult reading age of 18+, research shows many customers understand better when language is simplified to a reading age closer to 11 or 12. This shift helps ensure more people truly understand the products and services they use, reducing the risk of harm.

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Roger Miles

Roger researches behavioural risks in organisations, and advises senior leaders on how best to communicate risk and conduct matters. Previously, Roger ran risk communication programmes for professional bodies and the British Government. He now runs industry-level Academies for Conduct and Culture, and produces workshops with financial firms.

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